Arnold v. Dejoy

CourtDistrict Court, District of Columbia
DecidedSeptember 23, 2025
DocketCivil Action No. 2024-3499
StatusPublished

This text of Arnold v. Dejoy (Arnold v. Dejoy) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arnold v. Dejoy, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SHEON ARNOLD,

Plaintiff,

v. Civil Action No. 24 - 3499 (LLA)

DAVID STEINER,

Defendant.

MEMORANDUM OPINION

Plaintiff Sheon Arnold, proceeding pro se, filed a civil complaint in the Superior Court of

the District of Columbia against David Steiner in his official capacity as the Postmaster General

of the United States. ECF No. 1-2. 1 Before the court are Mr. Arnold’s motion to remand the case

to Superior Court, ECF No. 5, and the Postmaster General’s motion to dismiss, ECF No. 9. For

the reasons stated below, the court will deny Mr. Arnold’s motion to remand, grant the Postmaster

General’s motion to dismiss without prejudice, and allow Mr. Arnold to file an amended complaint

that cures the existing deficiencies within thirty days.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

In June 2024, Mr. Arnold filed a Superior Court complaint against the Postmaster General

alleging violations of the following laws: Title VII of the Civil Rights Act of 1964, 42 U.S.C

§ 2000e et seq., 18 U.S.C. § 1001 (a federal criminal statute pertaining to false statements and

entries); D.C. Code § 22-3241(1)(a)(2), (a District of Columbia forgery statute), and D.C. Code

1 Plaintiff named former Postmaster General Louis DeJoy as Defendant, but the current officer in this role is “automatically substituted” as a party pursuant to Federal Rule of Civil Procedure 25(d). § 47-4106(b) (a District of Columbia statute regarding fraud and false statements). See ECF

No. 1-2, at 5. 2 He seeks $82,000 in damages, plus interest. Id. at 1. The Superior Court docket

reflects that service was not effectuated on the Postmaster General consistent with D.C. Superior

Court Rules of Civil Procedure 4(i)(1) and 4(i)(2), which require a plaintiff serving a U.S. officer

or employee in their official capacity to send a copy of the service package to the U.S. officer or

employee, the U.S. Attorney General, and the U.S. Attorney General for the District of Columbia.

ECF No. 3, at 3; see Arnold v. Dejoy, 2024-CAB-3688 (D.C. Super. Ct.).

In December 2024, the Postmaster General removed the action to this court, ECF No. 1,

and Mr. Arnold filed a motion to remand, ECF No. 5. Because the Postmaster General contended

that the United States had not been properly served, he filed a motion in January 2025 asking the

court to stay the case until service was effected. ECF No. 4. The court granted the Postmaster

General’s motion, directed the U.S. Marshals Service to effectuate service, 3 and stayed the case

until service had been effectuated. ECF No. 6. After service was effectuated, ECF No. 8, the court

lifted the stay, May 19, 2025 Minute Order, and the Postmaster General filed a combined

opposition to Mr. Arnold’s motion to remand and motion to dismiss, ECF No. 9. Because

Mr. Arnold is proceeding pro se, the court issued a Fox/Neal order informing him that he needed

to respond to the Postmaster General’s motion to dismiss on or before August 7, 2025 or risk

having the motion granted as conceded. ECF No. 11; see Local Civ. R. 7(b). On August 4, Mr.

2 The citations to ECF Nos. 1-2, 5, and 8, refer to the ECF-generated page numbers at the top of each page, rather than any internal pagination. 3 The court directed the U.S. Marshals Service to effectuate service because the Superior Court had granted Mr. Arnold leave to proceed in forma pauperis. Order at 1, Arnold, 2024-CAB-3688 (D.C. Super. Ct. Sep. 13, 2024).

2 Arnold filed a reply in support of his motion to remand, ECF No. 12, but he did not respond to the

motion to dismiss.

II. DISCUSSION

A. Motion to Remand

Generally, “any civil action brought in a State court of which the district courts of the

United States have original jurisdiction, may be removed by the defendant . . . to the district court

of the United States for the district . . . embracing the place where such action is pending.” 28

U.S.C. § 1441(a). “Only state-court actions that originally could have been filed in federal court

may be removed to federal court by the defendant.” Caterpillar Inc. v. Williams, 482 U.S. 386,

392 (1987). A defendant must file his notice of removal within thirty days after receiving the

complaint “through service or otherwise.” 28 U.S.C. § 1446(b)(1). For purposes of the removal

statute, the Superior Court of the District of Columbia is a state court. Id. § 1451(1).

As relevant here, a civil action “that is commenced in a state court” may be removed to

federal court when it is against “[t]he United States or any agency thereof or any officer (or any

person acting under that officer) of the United States or any agency thereof . . . for or relating to

any act under color of such office.” Id. § 1442(a)(1). Federal district courts also have

subject-matter jurisdiction in “civil actions arising under the Constitution, laws, or treaties of the

United States” (federal question jurisdiction), id. § 1331, and over civil actions “between citizens

of different states” where the matter in controversy exceeds $75,000 (diversity jurisdiction), id.

§ 1332(a).

“A motion to remand the case on the basis of any defect other than lack of subject matter

jurisdiction must be made within 30 days after the filing of a notice of removal . . . .” Id. § 1447(c).

A motion to remand for lack of subject-matter jurisdiction may be made at any time. Id. The party

3 opposing remand bears the burden of showing that the federal court has subject-matter jurisdiction

and that removal was proper. See Simon v. Hofgard, 172 F. Supp. 3d 309, 315 (D.D.C. 2016).

Mr. Arnold first argues that the Postmaster General’s December 2024 removal was

untimely because it came six months after the case was filed. ECF No. 5, at 4. As noted, a

defendant has thirty days after receipt of the complaint, “though service or otherwise,” to file his

notice of removal. 28 U.S.C. § 1446(b)(1). The burden lies with the plaintiff to prove service.

Busby v. Cap. One, N.A., 932 F. Supp. 2d 114, 128 (D.D.C. 2013). In January 2025, the Postmaster

General contended that he had not been properly served. ECF No. 4. Mr. Arnold does not dispute

that service was not properly effectuated before the Postmaster General removed the action, nor

does he contend that the Postmaster General “otherwise” learned of the suit more than thirty days

before he removed the action in December 2024. Accordingly, Mr. Arnold has not shown that the

Postmaster General’s notice of removal was untimely.

Mr. Arnold next contends that remand is warranted because this case involves “fraud”

rather than “employment discrimination. See generally ECF No. 5. But when the defendant is a

United States officer or employee—like the Postmaster General is here—removal is permitted

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